By public info, this company is placed in Band F

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Ownership

PUBLIC

Defence revenue, USD

2bn (2013)

Defence revenue, %

38% (2013)

Country

SINGAPORE

Internal information

YES

Leadership 10%
1.
score
0

Does the company publish a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company?

Based on public information, there is no readily available evidence that the company publishes a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company.

COMMENTS -+
2.
score
0

Does the company’s Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company?

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

COMMENTS -+
3.
score
0

Does the company’s Chief Executive Officer demonstrate a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure?

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure.

COMMENTS -+
4.
score
1

Does the company publish a statement of values or principles representing high standards of business conduct, including honesty, trust, transparency, openness, integrity and accountability?

Based on public information, there is evidence that the company publishes a statement of values representing high standards of business conduct, including honesty and integrity. However, it does not cover the range of values sought by the question, or go into sufficient depth by explaining what they mean by such values and why they matter to the organisation. The company therefore scores 1.

COMMENTS -+
5.
score
0

Does the company belong to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption?

Based on public information, there is no readily available evidence that the company belongs to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption.

COMMENTS -+
6.
score
1

Has the company appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda?

Based on public information, the company has appointed the Audit Committee and the Risk Review Committee with overall corporate responsibility for its ethics and anti-corruption agenda. However, it is unclear how this responsibility is shared between the two committees. The company therefore scores 1.

COMMENTS -+
7.
score
0

Has the company appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda, and who has a direct reporting line to the Board?

Based on public information, it is unclear whether the company has appointed a senior person responsible for implementing the company’s ethics and anti-corruption agenda. TI notes the existence of the IA but it is unclear whether this fulfils the role.

COMMENTS -+
8.
score
0

Is there regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda?

Based on public information, the Board reviews the group’s top ten risks, of which adherence to anti-corruption legislation is a factor. However, TI does not assess this to be sufficient evidence of a review of the company’s ethics and anti-corruption agenda. In addition, it is unclear how often this exercise is undertaken.

COMMENTS -+
8a.
score
0

Is there a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, and evidence of improvement plans being implemented when issues are identified?

Based on public information, there is no readily available evidence to suggest the company has a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based.

COMMENTS -+
9.
score
0

Does the company have a formal process for review and where appropriate update its policies and practices in response to actual or alleged instances of corruption?

Based on public information, there is no readily available evidence that the company has a formal process to review and update its policies and practices in response to actual or alleged instances of corruption.

COMMENTS -+
Risk management 14%
9a.
score
0

Does the company have a formal anti-corruption risk assessment procedure implemented enterprise-wide?

Based on public information, there is no readily available evidence of a formal anti-corruption risk assessment procedure implemented enterprise-wide. The company has a risk profile which seems to include adherence to anti-corruption laws, but it is unclear whether this is implemented enterprise-wide.

COMMENTS -+
10.
score
0

Does the company have a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied?

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied.

COMMENTS -+
11.
score
0

Does the company conduct due diligence that minimises corruption risk when selecting or reappointing its agents?

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents.

COMMENTS -+
12.
score
1

Does the company have contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption?

Based on public information, there is evidence that the company has contractual rights for the behaviour of agents with respect to countering corruption. However, it is not clear that the company has formal monitoring and audit procedures in place and that contracts are terminated if corrupt activities are found. The company therefore scores 1.

COMMENTS -+
13.
score
1

Does the company make clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance?

Based on public information, there is evidence that the company makes clear to contractors through policy and contractual terms, its stance on bribery and corruption. However, it is not clear that the consequences of non-compliance are made clear. The company therefore scores 1.

COMMENTS -+
13a.
score
0

Does the company explicitly address the corruption risks associated with offset contracting?

Based on public information, there is no readily available evidence that the company explicitly addresses the corruption risks associated with offset contracting.

COMMENTS -+
13b.
score
0

Does the company conduct due diligence that minimises corruption risk when selecting its offset partners and offset brokers?

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting its offset partners and offset brokers.

COMMENTS -+
Policies & codes 17%
15.
score
1

Does the company have an anti-corruption policy that prohibits corruption in its various forms?

Based on public information, there is evidence that the company has an anti-corruption policy which seems to include terms on gifts and hospitality, conflicts of interest, bribery and political contributions. However, the full code of conduct is not publicly available and as such cannot be assessed. The company therefore scores 1.

COMMENTS -+
16.
score
2

Is the anti-corruption policy explicitly one of zero tolerance?

Based on public information, there is evidence that the company has a zero tolerance anti-corruption policy.

COMMENTS -+
17.
score
0

Is the company's anti-corruption policy easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company?

Based on public information, there is no readily available evidence that the company’s Anti-Corruption policy is easily accessible to Board members, employees and third parties, as it is not publicly available.

COMMENTS -+
17a.
score
0

Is the company’s anti-corruption policy easily understandable and clear to Board members, employees and third parties?

Based on public information, there is no readily available evidence that the company’s Anti-Corruption policy is easily understandable and clear to Board members, employees and third parties.

COMMENTS -+
18.
score
1

Does the anti-corruption policy explicitly apply to all employees and members of the Board?

Based on public information, the Code of Conduct and Ethics applies to all employees. However, there is no explicit mention of whether it applies to members of the Board. The company therefore scores 1.

COMMENTS -+
20.
score
0

Does the company have a policy on potential conflicts of interest, and does it apply to both employees and board members?

Based on public information, there is no readily available evidence that the company has a policy on potential conflicts of interest. The company makes several references to conflicts of interest. However, these are assessed to be limited statements, it is not clear what applies to employees and directors, and the statements made do not define what would constitute a conflict of interest.

COMMENTS -+
21.
score
0

Does the company have a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery?

Based on public information, there is no readily available evidence that the company has a policy for the giving and receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. The company’s Code of Business Conduct and Ethics makes reference to gifts and hospitality, but this document is not public and therefore could not be assessed.

COMMENTS -+
22.
score
0

Does the company’s anti-corruption policy include a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery?

Based on public information, there is no readily available evidence that the company has a policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. The company’s Code of Business Conduct and Ethics makes reference to gifts and hospitality, but this document is not public and therefore could not be assessed.

COMMENTS -+
23.
score
0

Does the company have a policy that explicitly prohibits facilitation payments?

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments.

COMMENTS -+
24.
score
0

Does the company prohibit political contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent? Does the company record and publicly disclose all political contributions?

Based on public information, there is no readily available evidence that the company prohibits political contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent. The company’s Code of Business Conduct and Ethics makes reference to political contributions and donations, but as the document is not publicly available, it was not possible to assess the policy.

COMMENTS -+
25.
score
0

Does the company have a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, and discloses the issues on which the company lobbies?

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, or discloses the issues on which it lobbies.

COMMENTS -+
25a.
score
0

Does the company prohibit charitable contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent?

Based on public information, there is no readily available evidence that the company prohibits charitable contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent.

COMMENTS -+
Training 0%
26.
score
0

Does the company provide written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda?

Based on public information, there is no readily available evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda.

COMMENTS -+
27.
score
0

Does the company have a training programme that explicitly covers anti-corruption?

Based on public information, there is no readily available evidence that the company has a training programme that explicitly covers anti-corruption.

COMMENTS -+
28.
score
0

Is anti-corruption training provided in all countries where the company operates or has company sites?

Based on public information, there is no readily available evidence that the company provides training in all countries where the company operates or has company sites.

COMMENTS -+
29.
score
0

Does the company provide targeted anti-corruption training to members of the Board?

Based on public information, there is no readily available evidence that the company provides anti-corruption training to members of the Board.

COMMENTS -+
30.
score
0

Does the company provide tailored ethics and anti-corruption training for employees in sensitive positions?

Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions.

COMMENTS -+
Personnel 21%
31.
score
0

Does the company have a clear and formal process by which employees declare conflicts of interest?

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest.

COMMENTS -+
32.
score
1

Is the company explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities?

Based on public information, there is evidence that employees who are found to be in violation of the Code of Business Conduct & Ethics may face disciplinary action. However, it is not clear whether this extends to members of the Board. Furthermore, the statement suggests that there may be exceptions. The company therefore scores 1.

COMMENTS -+
33.
score
0

Does the company have multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity?

Based on public information, there is no readily available evidence that the company has multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee, to report concerns or instances of suspected corrupt activity. TI notes that the company has a Whistleblowing Framework but limited information is provided.

COMMENTS -+
33a.
score
0

Are the whistleblowing channels available to all employees in all geographies?

Based on public information, there is no readily available evidence that the company provides whistleblowing channels to all employees in all geographies.

COMMENTS -+
33b.
score
0

Does the company have formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively?

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms to ensure that whistleblowing by employees is not deterred, or that whistleblowers are treated supportively.

COMMENTS -+
34.
score
0

Does the company have well-publicised resources available to all employees where help and advice can be sought on corruption-related issues?

Based on public information, there is no readily available evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues.

COMMENTS -+
35.
score
2

Is there a commitment to non-retaliation for bona fide reporting of corruption?

Based on public information, there is evidence that the company has a non-retaliation policy and that disciplinary measures are applied to employees who breach it.

COMMENTS -+
Band & analysis based on internal and public information: band D
Leadership 20%
Risk management 21%
Policies & codes 67%
Training 50%
Personnel 43%